How we implement The Modern Slavery Policy
If at any point we suspect or identify any cases of modern slavery, we commit to support the remediation of any victims – working with business partners, other brands, governments and NGOs as applicable. We also commit to assist law enforcement agencies with the investigation, identification and prosecution of any party that knowingly engages in or facilitates slavery or human trafficking.
1. Raising Awareness for Colleagues, Suppliers and Business Partners
In the summer of 2016, SuperGroup trained 169 supplier-facing colleagues and selected suppliers to raise awareness of our Modern Slavery Policy – to support the continued risk assessment and roll out of our due diligence processes.
In January 2017 we ran refresher training on this topic to support continued roll out of our policies to 40 supplier-facing colleagues.
This rolling training programme continues to support our cross business risk assessment and roll out plan of our Modern Slavery Policy.
2. Embedding human rights across our business
SuperGroup has a growing global team focused on Human Rights and wider Sustainability.
This team manages our ethical trading programme as well as progress towards environmental targets. We have established a number of mechanisms across our organisation to ensure human rights continue to be embedded in day to day business practice:
- We risk assess human rights impacts within our business and supply chain and adapt our programme to ensure any issues are addressed.
- We have established local resource in key sourcing countries to work closely with our suppliers’ factories and their subcontracted units.
- We have established robust ethical pre-approval processes for all main factory sites (Tier 1) and subcontracted units (Tier 2) to ensure we continue to work with the best possible partners.
- We regularly audit all main production sites (Tier 1) and their subcontracted units (Tier 2) on a semi-announced and unannounced basis.
- We provide training and support for factories to remediate any issues where identified. An example of this is that we are trialling ways of strengthening factory grievance mechanisms by working with locally based NGOs and former trade union representatives in India.
We continue to collaborate alongside other Ethical Trading Initiative members to support the development of best practice guidelines where industry wide risk has been identified.
3. Measuring the Effectiveness of our Ethical Trading Programme
We monitor the ongoing impacts of our ethical trading programme and report to our Executive Committee and Board of Directors regularly to provide continued oversight.
Targets in place for the next financial year include:-
- All supplier facing colleagues trained in Head Office on a rolling basis.
- Maintain ethical approval and monitoring processes for 100% of main production sites (Tier 1) and continue roll out to achieve 100% for all subcontracted units (Tier 2).
The above statement has been made pursuant to Section 54 of the Modern Slavery Act 2015 and California Transparency in Supply Chains Act of 2010 (SB657) and was approved and signed by Euan Sutherland, Chief Executive Officer, Superdry Plc (formerly SuperGroup Plc), on 10 August 2017.